In the post September 11, 2001, environment, federal regulatory attention has intensified in the arena of technological and biological security on university and college campuses.  The focus regulations are the USA Patriot Act, the CDC Select Agent Program and the several regulatory schemes known as “Export Controls,” specifically the State Department’s “International Traffic in Arms Regulations” (ITAR), the Commerce Department’s “Export Administration Regulations” (EAR), and the Treasury Department’s “Office of Foreign Assets Control” (OFAC) regulations.

Most college and university community members readily recognize the likelihood of controls on weapons technologies and exotic viruses; however, the application of export control regulations to conventional flows of information and materials in nonclassified university research activities and to commonplace research travels and shipments are not intuitive and straightforward.

In designing operational approaches to avoiding noncompliance with export controls, a variety of issues and scenarios specific to the campus should be identified, explored and addressed, including:

• Procedures and points of activity for transfers of materials, equipment, technologies
• International travel
• International funds flows
• Potential for “deemed export”
• Licensing processes
• Protection of the Fundamental Research Exclusion

Research Compliance Consulting can assist you with everything from risk assessment to designing practical policies, procedures and training/educational materials on export controls and their application to faculty, staff and students.